Modern slavery statement
Preventing slavery in our business
Aviva remains committed to respecting human rights in all its operations and external business dealings. Our commitment to human rights is reflected in our Human Rights Policy.
Aviva recognises modern slavery, servitude, forced or compulsory labour and human trafficking (“Modern Slavery”) as grave violations of many human rights and freedoms. Our Aviva Values compel us to take our responsibilities in this area seriously, in particular our values of Care More and Create Legacy.
As required by the Modern Slavery Act 2015 (the “Act”), this statement describes the steps Aviva plc has taken during the financial year ended 31 December 2017 to prevent modern slavery from taking place in our supply chains or within our own business.
About our business
Aviva provides life insurance, general insurance, health insurance and asset management to 33 million customers worldwide.
We have a strong international presence in selected insurance markets across North America, Europe and Asia. We're focused on markets and businesses where we can achieve scale, profitability and competitive advantage.
Aviva in the UK
We are one of the largest insurers with 15.5 million customers. Our UK-based businesses contribute 53% of our market operating profit (as at 30 June 2017). We offer a wide range of savings and investments, protection and insurance products to individuals, business and corporate customers. Our market share for general insurance is 10%, healthcare 13% and life insurance 15%.
Our customers can interact with us in a number of ways: online, by phone, through brokers, financial advisers, strategic partners and price comparison websites.
We have over 15,000 employees in the UK working across different locations including: London, Norwich, Bristol, Manchester, York, Perth, Sheffield, Birmingham and Glasgow.
Scope of our assessments in 2017
During 2017, we continued to focus our efforts on the Aviva entities registered in the UK and a sample of their suppliers that have a direct business relationship with Aviva, regardless of where these suppliers may be based.
A list of the Aviva entities identified in scope of the Act can be found within Annex 1 of this statement. In 2018, we will expand this scope to include non-UK Aviva entities.
During 2017 we have:
Continued to improve our existing policies
- We have now updated our Human Rights policy to include explicit reference to modern slavery.
Conducted due diligence on all of our managed suppliers
- We have engaged our UK managed supply base via our mandatory annual engagement on corporate responsibility.
- Building on our experience from 2016, we reviewed and improved the modern slavery supplier survey for 2017. The information obtained allows us to perform a better evaluation of risk in our supply chain, learn from and spread best practice and helps inform our priorities for engagement in 2018.
- We made changes to the procurement process to ensure that new suppliers (where UK Procurement are engaged in tender activity) are required to agree to abide by our Business Code of Behaviour and our Business Ethics Code. Both the Business Code of Behaviour and Business Ethics Code make explicit reference to modern slavery.
- Modern slavery is discussed in a forum which brings together stakeholders from each UK business unit and Supplier managers responsible for managing our highest risk category suppliers. This forum convenes regularly throughout the year.
Conducted a review of the standard clauses in supplier contracts
- We have reviewed our supplier contract template clauses on modern slavery to ensure they remain fit for purpose.
Delivered further training and engaged a wider audience
- We continued providing training on modern slavery to employees. We released an interview with our Group General Counsel, Aviva Investors Chief Responsible Investment Officer and the Group Facilities Director on human rights and modern slavery issues as part of employee and supplier communications and training. This recording describes Aviva’s commitment and actions on modern slavery, reporting mechanisms and how people can get more involved.
- We have created a page on our UK intranet dedicated to human rights and modern slavery to keep employees informed.
- Our UK employee representative group have also been engaged on modern slavery.
Reviewed data and begun developing potential indicators
- We conducted a review of current data sources available to track our performance in tackling modern slavery issues. We are aiming at testing a set of indicators in 2018. Potential indicators may include:
- Number of suppliers engaged on preventing modern slavery risks.
- Percentage of managed suppliers audited on their approach to managing modern slavery risks.
- Number of concerns regarding modern slavery reported through RightCall.
Collaborated with others
- In 2017, we continued working with the UN Global Compact. We are part of the UK working group on modern slavery which brings together peers from across different industry sectors to share learnings and information to support our work in tackling modern slavery.
- We are also a founding member of Business Against Slavery working group convened by the Home Office. This working group focuses on sharing learnings and working on tangible initiatives to combat modern slavery.
Employees, business partners, and suppliers with any concerns regarding modern slavery can report them through any of the following channels:
We are committed to continue improving our approach to respecting human rights and preventing modern slavery. In this context, in 2018 we will:
- Test indicators to track performance
- Consider pre-screening tools to assess suppliers before on-boarding
- Prioritise engagement on high risk suppliers based on the results of our 2017 survey
- Further explore the scope of our work in markets outside of the UK
Process followed to issue this statement
The boards of the Aviva entities identified within scope, as listed in Annex 1, as well as the Aviva plc Board, have approved this statement.
List of Aviva entities in scope of the Act
Aviva Insurance Limited
Aviva Annuity UK Limited
Aviva Central Services UK Limited
Aviva Employment Services Limited
Aviva Equity Release UK Limited
Aviva Europe SE
Aviva Group Holdings Limited
Aviva Health UK Limited
Aviva Investors Employment Services Limited
Aviva Investors Global Services Limited
Aviva Investors Pensions Limited
Aviva International Insurance Limited
Aviva International Holdings Limited
Aviva Investors UK Fund Services Limited
Aviva Life Holdings UK Limited
Aviva Life & Pensions UK Limited
Aviva Life Services UK Limited
Aviva UK Digital Ltd
Friends Life FPG Limited
Friends Life Holdings plc
Aviva Management Services UK Limited
Friends Life FPL Limited Friends Life and Pensions Limited Aviva Administration Limited Friends Life Limited
General Accident plc
Gresham Insurance Company Limited
Sesame Services Limited
Solus (London) Limited